1 Site Visit Report Nearman Creek Power Station 4240 North 55 th Street Kansas City , KS 66104 March 3 , 2009 1.0 Background and Objectives The Environmental Protection Agency (EPA) is in the process of developing 316(b) cooling water intake structure requirements that reflect the best technology available (BTA) for minimizing adverse environmental impact for all existing power plants and manufacturing facilities. As part of this process, EPA staff is visiting electric generators and manufacturers to b etter understand the cooling water intake structure (CWI S) technologies in use at ty pical facilities, including the site

- specific characteristics of each facility and how these affect the selection and performance of CWIS technologies. EPA is also visitin g facilities to better understand cooling water use and specific issues or technologies that can affect 316(b) compliance. Nearman Creek (Nearman) was selected for a site visit due to its location on a large freshwater river
. 2.0 Facility Description The Ne arman Creek Power Station is owned and operated by the Kansas City Board of Public Utilities (BPU) and is located in Wyandotte County in Kansas City , Kansas along the Missouri River. The facility is located on 800 acres. Nearman employ s approximately 60 people and began operation in 1981. Cooling and process water withdrawals from and wastewater discharges to the Missouri River are regulated under NPDES permit number KS 0119075 which expired on December 31, 2008. Nearman submitted its NPDES permit application in a timely

manner and is awaiting renewal of its permit by the state. 3.0 Electricity Generation and Transmission Nearman has one coal

- fired, steam

- electric generating unit with a generating capacity of 235 MW. It is a baseload unit with an ove rall capacit y utilization rate (CUR) of 5 0 %
. The fuel source is low

- sulfur coal from the Powder River Basin in Wyoming. The facility

has two routine maintenance outages that occur during the spring and fall. Ty picall y, the spring outage lasts for two weeks and the fall outage lasts one week.2

4.0 Cooling Water System and Intake Structure Nearman has one cooling water intake structure (CWI S) that provides once

through cooling water for the generating unit for a portion of the y ear . (As discussed in Secti on 6.0 below, Nearman operates a closed

- cycle cooling sy stem the remainder of the ye ar.) The CWI S is fitted with a trash rack and four standard (i.e., coarse mesh 3/8”) traveling screens. In addition , two circulating water pumps (one per two screens) , with a design intake flow (DIF) of 230 million gallons per day

( MGD ) , provide an average actual intake flow (AIF) of 153 MGD of cooling water to the generating unit. The through screen velocit y is 2.6 feet per second ( fps ) . The screens rotate when the press ure differential across the screen reaches a specified amount allowing for cleaning with a high pressure spray that flows into a debris trough which discharges to the Missouri River. Facilit y representatives indicated they have no issues with the CWI S or screen operation. In addition, as necessary , Nearman introduces warm water prior to the CWI S which effectivel y prevents icing. 1 Nearman does not have regularl y scheduled overhaul or maintenance periods for the CWI S. Rather, it performs CWI S maintenance and rebuild on an as

- needed basis. According to facility

representatives, river degradation 2 is the biggest issue facing Nearman. T h e water level of the Missouri River is also controlled by the Army Corps of Engineers. During low depth river conditions (winter), Nearman lacks adequate cooling water supply for its generating unit. In an effort to boost water intake during low flow conditions, Nearman installs temporary , supplemental pumps for its cooling water withdrawals
. 3 Nearman noted little problem with supplemental pump operation, but indicated the Corps requires removal prior to the summer
. Despite higher water levels in summer, the facility still curtails its generation, as water levels are substantiall y lower than when the facility was construct ed. 4 Because river degradation continues to occur, even after in corporation of supplemental pumps, Nearman continued to be concerned that the river level might not be able to adequately support its cooling water needs. As a result, Nearman installed close d

- cycle cooling. See Section 6.0
.

1 Nearman also provides a warm water line to the intake at the drinking water facility upstream. 2 The bottom of the river has eroded to a much lower depth. 3 These emergency pumps are installed at the river bottom (below the level of the bottom of the CWIS) and pum p water into the existing screenwell. 4 Higher ambient water temperatures also contribute to the derating.3

5.0 Impingement and Entrainment Information Nearman collected impingement samples in 2005. During the sampling period, Nearman conducted 24 hour impingement sampling every other week for a year for a total of 24 sampling events
. 5 In total, Nearman impinged 322 fish accounting for 1 8 species during the sampling events. Freshwater drum accounted for 4 0 % of the impinged fish. Based on these sampling results and similar data collected at Quindaro , Nearman estimates its annual impingement mortality to be 6 , 70 0 fish. This figure includes an adjustment to account for gizzard shad mortality not associated with impingement. Nearman based this adjustment on EPA Regional guidance. 6 Nearman has not conducted any entrainment or ambient sampling, but indicated that various other organizations have conducted ambient sampling of the Missouri River. 6.0 Cooling Tower Feasibility To ensure facility

operations would not be impacted by the quantity and temperature of river water available for cooling, Nearman began operating a fiberglass mechanical draft cooling tower consist ing of eight cells with standard Marley fill in a back

- to - back configuration (f our cells each side) in June 2006
. The tower is fitted with drift eliminators, but not plume or noise abatement controls. The closed

- cycle recirculating s ys tem ( CCRS ) retrofit cost Nearman $22 million. Facilit y representatives indicated there were no technical challenges associated with the retrofit, but that the costs included reinforcing the existing condenser to support the higher pressure associated with CCRS operation. 7 Nearman operates the CCRS for only part of the year (spring to the fall), when cooling water requirements and rive r temperatures are the highest. While operating, cit y water is the source of all make

- up cooling water (i.e., no water is withdrawn from the Missouri River for generator cooling water purposes ) . The CCRS sy stem requires 3600 gallons per minute ( GPM ) of m ake

- up water during full load on a hot summer day
. Nearman evaluated other sources of make

- up water, but elected to use city water because it would have had to treat river or well water for iron and manganese.

5 Facility representatives indicated that cooling water withdrawals during all sampling events w ere at least half of its AIF. 6 Based on a Missouri River study, young of the year gizzard shad become cold stressed and die when the river temperature reaches a specified amount (typically November to March). 7 Facility representatives noted that there was some damage to the condenser tubes that led to a forced outage.4 Nearman switches over to CCRS during its sp ring outage and switches off of the CCRS during its fall outage. T he transition is relatively eas y and t ypicall y requires 8
- 10 hours to fill the basin. Nearman operates the cooling tower at five cycles of concentration and adds 12.5% sodium hy pochlorite as a biocide
. Facilit y representatives noted that its CCRS is easy to operate and actuall y leads to slightly

better performance by

the generating units, as the return water from the tower is cooler than river water
. Facilit y representatives stated that they did not consider a helper tower configuration for the facility , as thermal discharges are not a problem. 7.0 Debris Handling Nearman does not have significant problems with debris loading. 8.0 Repowering/Future Uses Nearman has no current plans for re - powering or upgrades, but is considering the installation of low NO x burners next year. 9.0 Cooling Ponds There are no cooling ponds on site. 10.0 Ownership Nearman is owned by

the Kansas City

Board of Public Utilities. It is a public entity owned b y Kansas City . As such, the cit y government controls its rates and expenditures with the goal being that revenues raised equal to production costs (i.e., no profit). All capital funds are funded through bonds which must be approved b y an elected board of o fficials. 11.0 316(a) 316(a) is not an issue for Nearman. 12.0 Ash Handling Nearman sells all of its fly ash for re

- use. Nearman’s bottom ash is sluiced to an unlined pond . Nearman also has an on

- site landfill that dates back to its inception. It is clay

- lined and does not have a leachate collection sy stem. While the landfill is no longer used for this purpose, Nearman used to store bottom ash in it on occasion. Periodically , Nearman removes ash from the landfill which is subsequently

sent off site and u sed in mine reclamation activities. The as h pond is inspected annuall y b y the state.5

13.0 Air Emissions Controls Nearman operates an electronic precipitator with a removal efficiency of 99.6%. Additionally , Nearman is considering the installation of low NO x burners next ye ar. 14.0 Additional Information A consultant for Nearman provided data for estimated compliance costs for a number of Midwestern facilities that would be subject to Phase II requirements. Estimates were provided for technologies deemed feasib le and cost

- effective by the consultant. The data also includes estimates of benefits derived from the reduction in impingement. Attachments Attachm ent A List of Attendees Attachment B Aerial Photo s Attachment C Nearman Creek Power Station pamphlet Attachment D Aerial Photo of Nearman Creek During 1993 Flood Attachment E Estimated 316(b) Compliance Costs Attachment F Site Visit Photos6

Attachment A -- List of Attendees Paul Shriner, EPA Headquarters Jan Matuszko, EPA Headquarters Jamie Hurley , EPA Headquarters John Dunn, EPA Region VII Kelly Meadows, Tetra Tech Patrick Cassidy , Kansas City Board of Public Utilities Kira Bluebaum, Burns and McDonnell Gregory Howick, Burns and McDonnell7

Attachment B -- Aerial Photos Please see DCN 10

- 6524A accompanying this document Attachment C

—Nearman Creek Power Station pamphlet Please see DCN 10

- 6524B accompanying this document Attachment D -- Aerial Photo of Nearman Creek During 1993 Flood Please see DCN 10

- 6524C accompanying this document Attachment E -- Estimated 316(b) Compliance Costs Please see DCN 10

- 6524D accompanying this document Attachment F -- Site Visit Photos Please see DCNs 10
- 6524E through J accompan yi ng this document